Last Modified: November 15, 2014 v.1.0
At Sticky Brain Studios Inc. (“we”, “our”, “us”), protecting individuals’ personal information is a priority.
Because our online data collection activities are primarily targeted to parents and guardians, the practices and terms set forth in this Policy are mostly relevant and addressed to “you” as a parent or guardian. Therefore, all references to “you” or “your” refer to adult users, unless specifically noted otherwise. We have also developed a separate specific set of practices for the handling of any personal information we may collect online about children. These are outlined below.
- What is and what is not covered by this Policy
- The kinds of personal information we collect
- How and when we collect personal information
- How and when we use personal information
- How and when we may share personal information
- How cookies and other web technologies may be used
- How we protect your personal information
- Accessing and managing your personal information
- Further Information
1. What is and is what is not covered by this Policy
This Policy explains how Sticky Brain Studios Inc. collects and uses information from its users who use our services, including our treatment of personally identifiable information.
This Policy does not apply to websites or practices of companies that we do not own or control, or to individuals that we do not employ or manage. This Policy does not cover the Privacy Policies of third party application developers.
Other websites and services that may be accessible through links from the website may have their own privacy policies and practices. We encourage you to familiarize yourself with the privacy policies provided by these other parties prior to providing them with information or taking advantage of their services.
2. The kinds of personal information we collect
The information we collect through our services will generally fall into the following categories:
- Information that you voluntarily provide to us, namely:
- Contact Information such as your e-mail address or other information that allows us to directly or indirectly identify or contact you. If personal information is ever solicited or collected directly from children we will first seek verifiable parental consent.
- Information passively or automatically collected, namely:
- Technical Information which may include certain information or characteristics about your mobile device or web browser. This may include the type of operating system and web browser you use, your device’s Internet Protocol (IP) address, the names and versions of programs installed on your device, and information about the device itself, including product unique identifier, and product license information (i.e. information about the person or system licensed/authorized to use the product and/or its supporting software service locations). Technical information such as the types described above generally remains anonymous but in some cases can be linked to personal information associated with your account.
- Usage Information which may collectively include non-personal information about how you or your children use and interact with the basic functionalities of Sticky Brain Studios Inc.’s connected products or web-connected software applications (“product usage data”).
We do not collect any personal information via our mobile games or apps.
3. How and when we collect personal information
The specific types and amounts of information we collect will vary depending on your level of interaction with our services. The following are interactions you may have with Sticky Brain Studios Inc. where personal information is collected (and the kinds of information we collect during those interactions):
- Signing up to receive newsletters, product announcements;
- Marketing or other communications (Contact Information of the parent);
- Communicating with Sticky Brain Studios Inc. Customer Support (Contact Information of the parent);
In addition, we may collect certain Technical Information and browsing data relating to your use of Sticky Brain Studios website (such as the browser type you used on our web services, which web pages you visited, and how much time you spent on pages visited).
4. How and when we use personal information
Our primary use of your personal information is to communicate with you for technical support or for announcements of new products.
Depending on the information collected and the service for which it is collected, we may use the information we collect in the following ways:
- To send you communications such as welcome emails, newsletters, event announcements, parental notice or consent emails, recall announcements, or other similar transactional or administrative notices;
- For identification, eligibility, and security purposes, such as to help verify your identity when you confirm eligibility in a sweepstakes or contest;
- To conduct internal and external market analysis and research studies;
- To enable you to give us feedback on products and services; and,
- To otherwise improve and customize our products, services, and technologies to better meet your needs and the needs of your children.
5. How and when we may share personal information
Sticky Brain Studios Inc. may share your personal information and personal information associated with your child under your account, in the following situations:
- When we hire third party vendors to perform services on our behalf, such as helping us operate a website or online service, fulfill a contest or sweepstakes, administer surveys, process online transactions, execute and optimize marketing/advertising campaigns, and manage and enhance consumer data.
- Subject to your consent, when we partner with third party companies as part of a jointly-sponsored promotion or to offer you the ability to receive special offers and discounts directly from third party companies.
- If another legal entity acquires us, or if we go out of business, enter bankruptcy, or go through some other change of control.
- We reserve the right to access, read, preserve, and disclose any information that we reasonably believe is necessary to comply with law or court order; enforce or apply our conditions of use and other agreements; or protect the rights, property, or safety of our company, our employees, our users, or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction.
We take steps to ensure that our third party partners agree to protect the confidentiality and security of any personal information we share with them. We ensure that any third parties only obtain the personal information they need to perform the specific task they need to do and are prohibited from using the information for any other purpose. They must agree to keep your information confidential and secure and to meet or exceed the minimum legal requirements for protecting personal information in Canada and other jurisdictions such as the US.
6. How cookies and other web technologies may be used
Sticky Brain Studios Inc. uses a variety of standard technologies to generate statistics and information about traffic to and usage of our services. These technologies may include the following:
- “Log Files”that record web activity and gather statistics about your visit to or use of our services. Log files may capture, among other things: (i) your IP Address, which is a unique set of numbers assigned to your computer by your Internet Service Provider (ISP); (ii) the type of browser and operating system you use; (iii) other information about your online session, such as the URL you came from to get to our website and the date and time you visited our website or used our services; and, (iv) after parental confirmation, records of activity from Sticky Brain Studios enabled mobile apps.
7. How we protect your personal information
Sticky Brain Studios Inc. uses a variety of administrative and technical controls to protect the security of your personal information and to prevent it from being lost, destroyed, stolen, misused, or accessed by an unauthorized person. These measures include, but are not limited to:
- Storing your personal information in secure operating environments that are only accessible to authorized Sticky Brain Studios employees and vendors on a strict need-to-know basis;
- Verifying that any third parties with whom we may share personal information comply with or exceed the minimum legal requirements for protecting personal information in Canada or other jurisdictions such as the US.
8. Accessing and managing your personal information
If you have questions or requests, please contact us by email through Customer Support firstname.lastname@example.org. While we are ready to assist you, we cannot always delete records of past interactions and transactions. For example, we may be required to retain records for financial reporting and compliance reasons.
We will retain your information for as long as needed to provide you services and to maintain a record of your transactions for financial reporting purposes. If you wish to request that we no longer use your information to provide you services contact our Customer Support Centre. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
9. Accessing and Managing Your Children’s Personal Information
If a parent or guardian suspects that we have collected Children’s Personal Information relating to their child, the parent or guardian may confirm what information has been collected and may request that the information be deleted by emailing email@example.com via post at:
Sticky Brain Studios
Attn.: Privacy Officer
340 King Street East, 2nd Floor
Toronto, Ontario M5A 1K8
All of the practices and safeguards described in this Policy apply to the collection, use and disclosure of Children’s Personal Information in Sticky Brain Studios Inc.’s content. In addition, we adopt the following practices with respect to Children’s Personal Information:
- We will only knowingly solicit or collect Children’s Personal Information from partner sites done with parental consent.
- We will always ask for verifiable parental consent (e.g. an email from a parent or guardian) before collecting non-personally identifiable usage information (e.g. play data) from children associated with a parent’s or guardian’s account where that information can be linked to Children’s Personal Information associated with that account.
10. Further Information
Sticky Brain Studios Inc. operates in accordance with the rules and guidelines listed in the Personal Information Protection and Electronic Documents Act of Canada. For more information on the rules and guidelines of this act, please visit:
http://www.priv.gc.ca/leg_c/leg_c_p_e.asp to view the latest version of this legislation.